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A recent case highlights the severe consequences of an incorrect bill of lading (B/L) description, resulting in substantial financial losses.
Shenzhen Fangzhong Logistics faced a costly setback when a misdescription on the bill of lading led to cargo being detained at Santos Customs, ultimately causing the complete loss of an international trade order.
At the beginning of 2025, Shenzhen Fangzhong Logistics handled a 40GP shipment from Shenzhen to Santos, Brazil. Upon arrival, Brazil's SISCOMEX 2.0 system issued a red alert for customs review due to the B/L description stating “industrial parts” without specifying the brand. However, both the shipping documents and the cargo packaging displayed the “Siemens” trademark, which was not mentioned in the B/L. This discrepancy triggered a customs fraud investigation.
This B/L error resulted in the cargo being seized by customs on suspicion of smuggling, a 12-day unpacking and inspection process, the buyer canceling the order due to clearance delays, the seller incurring a total loss of USD 380,000 in cargo value and port demurrage fees, and the carrier being fined BRL 150,000 for failing to verify the packing list.
What is SISCOMEX 2.0?
As is widely known, Brazilian customs process documentation through the Siscomex system. If discrepancies arise between the bill of lading, commercial invoice, packing list, or other documents, the system may trigger an alert, requiring corrections and resubmission.
However, in January 2025, Brazil’s Federal Revenue Service officially launched the Real-time Bill of Lading Verification System (SISCOMEX 2.0). Any B/L errors will now immediately trigger a customs red-light review, resulting in a minimum 5-day delay in clearance and a potential fine.
What Are the New SISCOMEX 2.0 Regulations?
Starting in 2025, Brazilian customs mandates full consistency among the electronic bill of lading, commercial invoice, and packing list for the following fields:
1. Brand/Model:
o The bill of lading, invoice, and packing list must state both brand name and trademark registration number.
o For non-branded products, it must explicitly state "Generic Product."
2. First 6 digits of the HS Code
3. Net Weight (allowable discrepancy: ≤3%)
How to Rectify B/L Errors Under the New Rules?
1. 24-Hour Correction Window:
o If an error is detected, it can be corrected before arrival using the SISCOMEX 2.0 “Rapid Correction Channel” (limited to one correction per B/L, processing time ≤2 hours).
o If corrections are made after the 24-hour arrival window, a fine of USD 500 per hour applies.
2. Notarization & Blockchain Recordkeeping:
o Correction documents must be notarized by a Brazilian notary office and uploaded to the customs blockchain.
o Recommended platform: Notary Chain (users should retain screenshot proof of operation).
3. Purchase liability insurance:
It is recommended to purchase comprehensive freight insurance (including customs delay liability) to cover the extra cost during the detention of the goods (minimum coverage: USD 500,000 per B/L).
Risk warning :Customs regulations on bills of lading are particularly strict in certain South American countries, including Brazil, Argentina, and Venezuela etc. ,
Practical advice :Consignors should understand and pay attention to the restrictions of the bill of lading in advance.
For a detailed discussion of Brazilian B/L risks, refer to a JC platform risk management interview featuring insights from a local Brazilian logistics agent:
JC Risk Prevention & Risk Sharing – Brazil
In 2025, , we will also release customs clearance guidelines for bills of lading under the new regulations of Brazil and South American countries.Continue to focus on the JCtrans risk control platform.
